ML20125B158

Second Suppl to 850301 Response to Case 850204 Request for Admissions.Sser 10 Which Addresses Mechanical/Piping Issues Now Places NRC in Position to Respond to Requests 28-33. Certificate of Svc Encl.Related Correspondence

ML20125B158
Person / Time
Site:	Comanche Peak
Issue date:	06/07/1985
From:	Berry G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Atomic Safety and Licensing Board Panel
References
CON-#285-362 OL-2, NUDOCS 8506110333
Download: ML20125B158 (7)

Text

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., RECATED CORRESPONDENCE g.

June 7, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION M

BEFORE THE ATOMIC SAFETY AND LICENSING' BOARD u C 4 In the Matter of ) '85 JUN 10 A11 :55 TEXAS UTILITIES ELECTRIC 2 .

COMPANY, et al. ) Docket Nos. 50-445/ g g.. _ _ ~y. ,,fi[j %

50-446/

BRMiCH (Comanche Peak Steam Electric Station, Units 1 and 2)

SECOND SUPPLEMENT TO NRC STAFF RESPONSE TO CASE'S REQUEST FOR ADMISSIONS I. INTRODUCTION On February 4, 1985, Intervenor Citizens Association for Sound Energy (CASE) filed a request for admissions in which it asks the Staff to admit certain facts purportedly found by the Staff's Technical Review Team (TRT) during the course of its review and evaluation of Applicants' construction and ouality assurance / quality control activities at Comanche Peak Steam Electric Station (CPSES). In its March 1, 1985 Response the Staff indicated that the TRT's findings and conclusions regarding the matters within its jurisdiction are set forth in applicable Supplemental Safety Evaluation Reports (SSERs). See Staff Response at 2-3. At the time the Staff's March 1 Response to CASE'S Admission requests was filed only the SSER concerning Electrical / Instrumentation and Test Program issues had been published. Subsequently, the Staff issued SSER No.10, which addresses Mechanical / Piping issues. Consequently, the Staff is now 1

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'y - in a position to respond to CASE admission requests 28-33 which relate to these matters. The Staff's responses are set forth below.

II. NRC STAFF RESPONSE TO SPECIFIC ADMISSION REQUESTS

28. The TRT found that no fillet weld inspection criteria existed for certain types of skewed welds. The TRT found that Brown & Root weld inspection procedures CP-QAP-12.1 and QI-QAP-11.1-28 for NF supports did not address some types of skewed welds. Although [the] TRT was told by Brown & Root personnel that procedure QI-QAP-11.1-26 for piping weld inspection was used, no evidence documenting the use of this inspection procedure was provided to the TRT. The lack of inspectioti criteria and lack of verification of proper inspection procedures being conducted for some types of skewed welds [is] a violation of ASME Code for NF supports committed to by TUEC in FSAR Section 5.2.1 and violation of Criterion XVII in Appendix B of 10 C.F.R. 50.

STAFF RESPONSE: Admit. See SSER No. 10 at N-204, 205.

29. The TRT found that, although the small sample of welds inspected by the TRT are acceptable, due to deficiencies in inspection records and the apparent lack of inspection criteria [for NF supports], the TRT is not certain whether some types of skewed welds were inspected properly.

The lack of documented inspections and criteria for some types of skewed welds in NF supports represents a safety concern regarding the possible existence of under-sized welds in supports which are required to resist various design load.

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STAFF RESPONSE: Admit. See SSER No. 10 at N-204, 205.

30. The TRT attempted to review TUEC records for ultrasonic (UT) measurement results and general installation practices. The TRT was told that ultrasonic testing of these types of bolts was not a procedural requirement; however, TUEC was unable to provide any other installation records for TRT review. The TRT concludes that this lack of installation inspection records is a violation of QA procedures and Criterion XVII in Appendix B of 10 C.F.R. 50.

STAFF RESPONSE: Admit only that CASE Admission Request 30 fairly reflects paragraph V-(b) of the Staff's November 29, 1984 letter to TUEC which requested the firm to provide additional information.

In the course of evaluating the allegation that the bolts used to install the upper steam generator lateral supports were cut to conform to applicable thread engagement requirements, the TRT found that "TUEC was unable to provide an inspection record or traveler package documenting the installation of the bolts. . . ." SSER No. 10 at N-149. Although the TRT found that the cutting of bolts "had no technical merit," id.

at N-150, the TRT concluded "that the absence of installation inspection records creates a potential safety and QA/QC concern, since these beams are required for restraint of the [ steam generator] during a seismic and pipe rupture event." ]_d.atN-151. Accordingly, the TRT required TUEC to find the original QA/QC inspection and installation records for the restraint in question. Id. If TUEC was unable to retrieve the records in question, TUEC was required by the TRT to " provide evidence such a_ss

i ultrasonic measurement results, to verify acceptable bolt length." Id.

(emphasis added).

31. The TRT, in reviewing the SRT findings in the area of piping design considerations, has discovered that piping systems, such as Main Steam, Auxiliary Steam and Feedwater, are routed from the Electrical Control Building'(seismic category I) to the Turbine Building (non-seismic category I) without any isolation. To'be acceptable, each seismic category I piping system should be isolated from any non-seismic category I piping system by separation, barrier or constraint.

STAFF RESPONSE: Admit. See SSER No. 10 at N-238.

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32. Region IV inspections have confirmed the existence of plug welds in cable tray supports located in the Unit 2 Cable Spreading Room.

STAFF RESPONSE: Admit. See SSER No. 10 at N-64.

33. The TRT determined that the alleged incident pertained to restoration of the Unit 1, loop 1 main steam line to its initial, correct installation position. (The line had shifted during flushing operations due to the weight of the added water and because the temporary supports sagged.) The TRT also determined that the modifications to permanent pipe supports were necessary to provide proper support to the main steam line in its restored position (initial designs for and construction of the supports had been based on the shifted position of the line) and, although the alleged vibrations could not be confirmed, their associated stresses might not have damaged the main steam line. The TRT review of a

y TUEC analysis, performed 1 year after the incident, concluded that the analysis was incomplete. An evaluation for the full sequence of events leading up to the incident had not been performed. The TRT review of Gibbs & Hill Specification No. 2323-MS-100 indicated that there were inadequate requirements and construction practices for the support of the main steam line auring flushing, and for temporary supports for piping and equipment in general. In particular, evaluations to assure the adequacy of temporary supports during flushing and installation were not required.

STAFF RESPONSE: Admit. See SSER No. 10 at N-107-108.

Re pctfully submitted, regory A/lan U trry r i Counsel h r Nk Staff I Dated at Bethesda, Maryland this 7th day of June,1985 l

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UNITED STATES OF AMERICA' NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

00CHETED

) MNRC TEXAS UTILITIES ELECTRIC COMPANY, ) Docket Nos. 50-445/2 et al. ) 50-446/2 E JtJN 10 A11:55 l

(Co n e Peak Steam Electric Station, Units-1 and 2) )

0FflCE Cf SECtIdA6 r 00CKETING & SERvia.

BRANCH CERTIFICATE OF SERVICE I hereby certify that copies of "SECOND SUPPLEMENT TO NRC STAFF RESPONSE TO CASE'S REQUEST FOR ADMISSIONS"_in the above-captioned proceeding have been_ served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 7th day of June,1985:

Peter B. Bloch, Esq., Chairman

• Mrs.Juanita Ellis Administrative Judge . . President.. CASE ,

4 Atomic Safety and Licensing Board 1426 South Polk Street U.S. Nuclear Regulatory Commission Dalla:;, TX 75224 Washington, DC 20555 Renea Hicks, Esq.

Herbert Grossman, Alternate Chairman

• Assistant Attorney General Administrative Judge Environmental Protection Division Atomic Safety and Licensing Board P. O. Box 12548, Capital Station U.S. Nuclear Regulatory Commission Austin, TX 78711

- Washington, DC. 20555 Nicholas S. Reynolds, Esq.

Dr. Walter H. Jordan William A. Horin, Esq.

Administrative Judge Bishop, Liberman, Cook, 881 W. Outer Drive Purcell & Reynolds Oak Ridge, TN - 37830 1200 17th Street,N.W.

Washington, DC 20036 Dr. Kenneth A. McCollom

. Administrative Judge Mr. James E. Cummins

-Dena, Division of Engineering, Resident Inspector / Comanche Peak Architecture and Technology Steam Electric Station Oklahoma State University c/o U.S. Nuclear Regulatory Commission Stillwater, OK 74078 P. O. Box 38 Glen Rose, TX 76043 1

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9 Robert D. Martin Billie Pirner Garde William L. Brown, Esq. Citizens Clinic Director U.S. Nuclear Regulatory Commission Government Accountability Project 611 Ryan Plaza Drive, Suite 1000 1901 Que Street, N.W.

Arlington, TX 76011 Washington, DC 20009 Mr. Michael D. Spence, President Robert A. Wooldridge, Esq.

Texas Utilities Electric Company Worsham, Forsythe, Sampels &

Skyway Tower Wooldridge

~400 North Olive Street, L.B. 81 2001 Bryan Tower, Suite 2500 Dallas, TX 75201 Dallas, TX 75201 Lanny Alan Sinkin Atomic Safety and Licensing Board 3022 Porter Street, N.W., #304 Board Panel

• Washington, DC 20008 U.S. Nuclear Regulatory Commission Washington, DC 20555 Joseph Gallo, Esq.

Isham, Lincoln & Beale Anthony Z. Roisman, Esq.

Suite 840 Trial Lawyers for Public Justice 1120 Connecticut Avenue, N.W. 2000 P Street, N.W., Suite 611 Washington, DC 20036 Washington, DC 20036 Ellen Ginsberg, Esq.* Atomic Safety and Licensing Appeal Atomic Safety and Licensing Board Board Panel

• U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comission Washington, DC 20555 Washington, DC 20555 Docketing and Service Section* Elizabeth.B. Johnson Office of the Secretary Administrative Judge U.S. Nuclear Regulatory Commission Oak Ridge National Laboratory Washington, DC 20555 P. O. Box X, Building 3500 Oak Ridge, TN 37830 Eregory A)Dn cry

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Counsel fR N Staff '

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